Tag: Energy Storage

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Trade Group Complains that PJM’s Frequency Regulation System Unduly Discriminates Against Energy Storage Resources
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WUTC Proposes Changes to Planning Paradigms and IRP Models for Energy Storage Technologies
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MassCEC Solicits Proposals for Innovative Energy Storage Uses Cases and Business Models
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FERC Issues Order Extending Deadlines for Energy Storage Comments
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Oregon PUC to Hold Energy Storage Workshop on May 9, 2016
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FERC Staff Seeks Comments on Participation of Electric Storage Resources in Wholesale Electricity Markets

Trade Group Complains that PJM’s Frequency Regulation System Unduly Discriminates Against Energy Storage Resources

By William M. Keyser, Molly Suda, and Michael L. O’Neill                     

The Energy Storage Association (ESA) filed a complaint with the Federal Energy Regulatory Commission (FERC or Commission) alleging that PJM Interconnection, L.L.C. (PJM) has adjusted its system operations to unduly discriminate against certain market participants.  ESA argues that PJM changed the rules of its frequency regulation market, without prior FERC approval, and that those rule changes unduly discriminate against limited energy resource participants, such as energy storage providers.

FERC has set May 15, 2017, as the deadline for parties to comment, intervene, or protest ESA’s complaint.  Commenting and/or intervention are important procedural tools that allow interested parties to protect and advocate for their interests.  Given the potentially broad impact of this complaint on PJM’s energy and frequency regulation market design, numerous entities may seek to participate in this proceeding.  K&L Gates will continue to follow this proceeding closely.

To read the full alert on K&L Gates HUB, click here.

WUTC Proposes Changes to Planning Paradigms and IRP Models for Energy Storage Technologies

By Vanessa Pronovost, Eric Jay, Molly Suda, and William Holmes

The Washington State Utilities and Transportation Commission (the “WUTC”) has issued a Draft Report and Policy Statement on Treatment of Energy Storage Technologies in Integrated Resource Planning and Resource Acquisition (the “Draft Report”) in connection with two consolidated dockets, UE-151069 and U-161024 (the “Dockets”).  The Draft Report is intended to provide useful guidance regarding energy storage technologies to investor-owned utilities (“IOUs”), vendors seeking to promote energy storage for use by IOUs, and anyone interested in the use of energy storage on electric distribution systems.  The WUTC is seeking comments to the Draft Report by 5:00 pm on Monday, April 3, 2017 for the WUTC’s consideration in preparing its final policy statement on the Dockets.

Before issuing the Draft Report, the WUTC held two formal workshops and solicited two rounds of comments.  Commenters generally agreed that current integrated resource planning (“IRP”) models are inadequate for purposes of capturing the benefits of energy storage technologies.  The following is a summary of the WUTC’s conclusions and guidance with respect to investments in energy storage technologies.

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MassCEC Solicits Proposals for Innovative Energy Storage Uses Cases and Business Models

By William H. Holmes, Molly Suda, and Michael L. O’Neill

On March 9, 2017, the Massachusetts Clean Energy Center (MassCEC) issued a Request for Proposals for the “Advancing Clean Energy Storage” (ACES) Program.  MassCEC is offering up to $10 million in funding for energy storage demonstration projects that “pilot innovative, broadly replicable energy storage use cases/business models with multiple value streams in order to prime Massachusetts for increased commercialization and deployment of storage technologies.”  The organization expects to make 10-15 awards of between $100,000 and $1,250,000 each. Applications are due to MassCEC by 4 pm Eastern Time on June 9, 2017.

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FERC Issues Order Extending Deadlines for Energy Storage Comments

As an update to our earlier post on FERC’s latest proceeding related to electric storage resources, on April 27, 2016, FERC issued an order extending the deadline for RTOs and ISOs to submit their responses to FERC’s data requests.  The RTOs’ and ISOs’ responses are now due on May 16, 2016.  FERC also granted an extension to June 6, 2016 for other comments.

Oregon PUC to Hold Energy Storage Workshop on May 9, 2016

The Public Utility Commission of Oregon (the “Commission” or “OPUC”) has scheduled a workshop on May 9, 2016 to assist the Commission with its task of adopting guidelines that utilities are to use when drafting and submitting energy storage proposals under House Bill (HB) 2193.  The workshop was scheduled in response to a Commission-request at the March 30, 2016 prehearing conference in Docket No. UM 1751, which was opened in compliance with HB 2193.  At the prehearing conference, Administrative Law Judge Ruth Harper informed the parties that the Commission wanted the proceeding to start with a Commission workshop to address the purpose and content of the guidelines, as well as the range of viable projects.    Read More

FERC Staff Seeks Comments on Participation of Electric Storage Resources in Wholesale Electricity Markets

Last week, the Federal Energy Regulatory Commission (“FERC”) opened a proceeding in Docket No. AD16-20 for FERC Staff to consider a wide range of issues related to electric storage resources, including whether barriers exist in the United States’ organized wholesale energy markets that are frustrating the participation of electric storage resources in those markets and leading to unjust and unreasonable wholesale electricity prices.  The new proceeding was also a topic of discussion during FERC’s monthly meeting on Thursday, April 21, 2016, with each Commissioner expressing significant interest in the energy storage issues to be considered and studied by FERC Staff.  For purposes of the proceeding, FERC Staff has taken a broad view of electric storage resources, defining such resources to include all facilities “that can receive electric energy from the grid and store it for later injection of electricity back to the grid . . . regardless of their size and storage medium, or whether they are interconnected to the transmission system, distribution system, or behind a customer meter.”

To kick-off the proceeding, FERC Staff sent letters to California Independent System Operator Corp., ISO New England, Inc., Midcontinent Independent System Operator, Inc., New York Independent System Operator , PJM Interconnection L.L.C., and Southwest Power Pool, Inc. (collectively, the “RTOs and ISOs”), requesting that by May 2, 2016, they submit information about current market rules and procedures applicable to electric storage resources’ participation in each respective market.  In a concurrent notice issued in the same docket, FERC Staff also invited other comments on whether current market rules are blocking the participation of electric storage resources in the organized markets and whether there are specific rule changes that could facilitate the participation of such resources.  FERC Staff is asking other commenters to specifically address the RTOs’ and ISOs’ May 2, 2016 responses, and  set May 23, 2016 as the deadline for such other comments.  The types of data requested from the RTOs and ISOs and the related topics on which FERC Staff is seeking comment are outlined below.

  • Eligibility to participate in the organized wholesale electric markets. FERC Staff has asked each of the RTOs and ISOs to explain whether electric storage resources are currently eligible to participate in capacity, energy, and/or ancillary services markets, and if not, what justifies their ineligibility.  FERC Staff is also seeking comments on whether clarification of particular market rules or tariff provisions would remove undue barriers to the participation of electric storage resources.
  • Minimum technical criteria and performance requirements to participate in the organized wholesale electric markets. In addition to requesting information from the RTOs and ISOs on the current technical criteria and performance requirements (e.g., minimum capacity sizes, bid sizes, or run times) that must be met to participate in the wholesale markets, FERC Staff is seeking input on whether certain technical criteria or performance requirements are unjustified and unfairly prevent market participation by electric storage resources.   FERC Staff has also requested input on alternative minimum criteria or eligibility requirements and the potential effect of such alternatives on system reliability and market operations.
  • Bid parameters applicable to electric storage resources. The operational capabilities of electric storage resources to receive, store, and later sell electricity distinguish electric storage resources from conventional generation.  Thus, FERC Staff is seeking input on whether current market rules for bid parameters could and should be revised to better reflect electric storage resources’ operational capabilities, and whether making such revisions would improve RTOs’ and ISOs’ ability to model and dispatch electric storage resources.  Given the broad array of technologies encompassed by FERC Staff’s definition of electric storage resources, FERC Staff also asks that commenters address whether specific technologies warrant different bid parameters or whether a general set of rules could apply to all types of electric storage resources.
  • Electric storage resources interconnected at the distribution level and aggregation of electric storage resources. FERC Staff recognized that electric storage resources may be able to participate in the wholesale markets despite being interconnected at the distribution level.  Therefore, FERC Staff is seeking input on what market opportunities are or should be available for distribution-connected electric storage resources and the impact of electric storage resources participating in the wholesale markets while simultaneously providing distribution-level services.  FERC Staff has also asked the RTOs, ISOs, and other commenters to address opportunities and means to aggregate multiple electric storage resources into a single resource that serves as the wholesale market participant.
  • Energy purchases by electric storage resources and pricing of energy purchases by electric storage resources. FERC Staff asked the RTOs and ISOs to explain the current bid requirements for electric storage resources that are purchasing energy and whether they must pay the locational marginal price for their energy purchases or instead pay a different rate for their receipt of energy from the grid.  FERC Staff is also interested in understanding whether the appropriate pricing of energy purchases may be affected by what services the electric storage resources are providing or whether the electric storage resources is interconnected to the transmission system, distribution system, or behind the meter.

This proceeding is yet another signal that energy storage issues are at the forefront of FERC’s regulatory initiatives.  As noted in a prior blog post, FERC is already scheduled, in a technical conference on May 13, 2016, to address issues and potential impediments to the interconnection of electric storage resources.  Parties interested in the development and deployment of electric storage resources will want to be involved in these proceedings and keep a close eye on the issues raised by commenters.  These proceedings and the issues spotlighted for FERC could be precursors to new rulemakings and regulatory changes with the potential to affect the development and direction of new or expanded markets and revenues streams for electric storage resources.   We will certainly be monitoring these proceedings and will keep you posted.

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